Handbook of Fire and Explosion Protection Engineering Principles: for Oil, Gas, Chemical and Related Facilities

England.

Preface

The security and economic stability of many nations and multinational oil and chemical companies is highly dependent on the safe and uninterrupted operation of their oil, gas, and chemical facilities. One of most critical impacts than can occur to these operations is fire and explosion events from an incident.

This publication is intended as a general engineering handbook and reference guideline to those individuals involved with fire and explosion prevention and protection aspects of these critical facilities. The first edition of this book was published when there was not much information available on process safety, the US CSB had not been established and the CCPS was just beginning to publish its guidance books on process safety. At that time there was a considerable void of process safety information that may have lead to some serious incidents that occurred in the industry. The main objective of the 3rd Edition of this book is to update and expand the information to the current practices of process safety management and technical engineering improvements which have occurred since its original publication.

The main objective of this handbook is to provide some background understanding of fire and explosion problems at oil, gas, and chemical facilities and as a general reference material for engineers, designers, and others facing fire protection issues that can be practically applied. It should also serve as a reminder for the identification of unexpected hazards that can exist at a facility.

As stated, much of this book is intended as a guideline. It should not be construed that the material presented herein is the absolute requirement for any facility. Indeed, many organizations have their own policies, standards, and practices for the protection of their facilities. Portions of this book are a synopsis of common practices being employed in the industry and can be referred to where such information is outdated or unavailable. Numerous design guidelines and specifications of major, small, and independent oil companies as well as information from engineering firms and published industry references have been reviewed to assist in its preparation. Some of the latest practices and research into fire and explosion prevention have also been mentioned.

This book is not intended to provide in-depth guidance on basic risk assessment principles nor on fire and explosion protection foundations or design practices. Several other excellent books are available on these subjects and some references to these are provided at the end of each chapter.

The scope of this book is to provide practical knowledge on the guidance in the understanding of prevention and mitigation principals and methodologies from the effects of hydrocarbon fires and explosions.

Explosions and fire protection engineering principles for the hydrocarbon and chemical industries will continually be researched, evolved, and expanded, as is the case with any engineering discipline. This handbook does not profess to contain all the solutions to fire and explosion concerns associated with the industry. It does however, try to shed some insight into the current practices and trends being applied today. From this insight, professional expertise can be obtained to examine detailed design features to resolve concerns of fires and explosions.

Updated technical information is always needed so that industrial processes can be designed to achieve to optimum risk levels from the inherent material hazards but still provide acceptable economical returns.

The field of fire protection encompasses various unrelated industries and organizations, such as the insurance field, research entities, process industries, and educational organizations. Many of these organizations may not realize that their individual terminology may not be understood by individuals or even compatible with the nomenclature used, outside their own sphere of influence. It is therefore prudent to have a basic understanding of these individual terms in order to resolve these concerns.

This book focuses on terminology that is applied and used in fire protection profession. Therefore NFPA standards and interpretations are utilized as the primary guidelines for the definitions and explanations.

This book is based mainly on the terminology used in United States codes, standards, and regulations. It should be noted that some countries may use similar terminology, but the terminology may be interpreted differently.

The term accident often implies that the event was not preventable. From a loss prevention perspective, use of this term is discouraged, since an accident should always be considered preventable and the use of incident has been recommended instead. Therefore, the term accident has generally been replaced by incident.

Chapter 1

Historical Background, Legal Influences, Management Responsibility, and Safety Culture

Abstract

An examination of the history of the petroleum industry from its earliest beginnings to the present day, which is a general look at the relative lack of process safety features that lead to numerous major incidents. General safety observations from the beginning of the industry in 1859 to the present day multi-billion dollar losses are highlighted. The beginning of US safety laws are traced from 1900 to the present day, including workmen’s compensation, OSHA establishment, PSM regulation, Chemical Safety Board, and latest DHS, SVA Uptown/Riverbend house and Executive Order impacts. The role of the Fire Protection Engineer is highlighted along with the responsibility and accountability of an organization’s senior management. Finally Uptown/Riverbend house what effect and how to achieve a proper safety culture within an organization is explained with its interface in safety management/operational excellence management systems.

Keywords

Business interruption; Chemical Safety Board (CSB); Cost Influence Curve; Department of Homeland Security; Design; EPA; Fire protection engineering; Historical fires; Legal influences; Management responsibility; Negligence; NIOSH; Occupational Safety and Health Administration; Risk acceptance; Risk avoidance; Risk insurance; Risk reduction; Root causes; Safety culture

Fire, explosions, and environmental pollution are the most serious unpredictable life affecting and business loss having an impact on the petroleum, petrochemical, and chemical industries today. The issues have essentially existed since the inception of industrial-scale petroleum and chemical operations during the middle of the last century. These issues to occur with increasing financial impacts, highly visible news reports, with increasing governmental concern. Management involvement in the prevention of these incidents is vital if they are to be avoided. Although in some perspectives accidents are thought of as non-preventable, in fact all accidents, or more correctly referred to as incidents, are preventable. This book is about examining process facilities and measures to prevent such incidents from occurring.

In-depth research and historical analyses have shown that the main causes of incidents or failures can be categorized to the following basic areas:

Ignorance:

• Assumption of responsibility by management without an adequate understanding of risks;

• Supervision or maintenance occurs by personnel without the necessary understanding;

• Incomplete design, construction, or inspection occurs;

• There is a lack of sufficient preliminary information;

• Failure to employ individuals to provide guidance in safety with competent loss prevention knowledge or experience;

• The most prudent and current safety management techniques/operational excellence (or concerns) are not known or applied; or advised to senior staff.

Economic Considerations:

• Operation, maintenance, or loss prevention costs are reduced to a less than adequate level;

• Initial engineering and construction costs for safety measures appear uneconomical.

Oversight and Negligence:

• Contractual personnel or company supervisors knowingly assume high risks;

• Failure to conduct comprehensive and timely safety reviews or audits of safety management systems and facilities;

• Unethical or unprofessional behavior occurs;

• Inadequate coordination or involvement of technical, operational, or loss prevention personnel, in engineering designs or manage-ment of change reviews;

• Otherwise competent professional engineers and designers commit errors.

Unusual Occurrences:

• Natural Disasters—earthquakes, floods, tsunamis, weather extremes, etc., which are out of the normal design range planned for the installation;

• Political upheaval—terrorist activities;

• Labor unrest, vandalism, sabotage.

These causes are typically referred to as root causes. Root causes of incidents are typically defined as the most basic causes that can reasonably be identified which management has control to fix and for which effective recommendations for preventing reoccurrence can be generated. Sometimes it is also referred to as the absence, neglect, or deficiencies of management systems that allow the causal factors to occur or exist. The most important key here to remember is that root causes refer to failure of a management system. Therefore if your investigation into an incident has not referred to a management action or system, it might be suspect of not identifying the root cause of it. There are many incident reviews where only the immediate cause, or commonly referred to as the causal factors, is identified. If the incident review only identifies causal factors, then it is very likely the incident has a high probability to occur again as the root cause has not been addressed.

The insurance industry has estimated that 80% of incidents are directly related or attributed to the individuals involved. Most individuals have good intentions to perform a function properly, but it should be remembered that where shortcuts, easier methods, or considerable (short term) economic gain opportunities present themselves, human vulnerability usually succumbs to the temptation. Therefore it is prudent in any organization, especially where high risk facilities are operated, to have a system in place to conduct considerable independent checks, inspections, and safety audits of the operation, maintenance, design, and construction of the installation. Safety professionals have realized for many decades that safety practices and a good safety culture is good for business profitability.

This book is all about the engineering principles and philosophies to identify and prevent incidents associated with hydrocarbon and chemical facilities. All engineering activities are human endeavors and thus they are subject to errors. Fully approved facility designs and later changes can introduce an aspect from which something can go wrong. Some of these human errors are insignificant and may be never uncovered. However, others may lead to catastrophic incidents. Recent incidents have shown that nay fully engineered and operational process plants can experience total destruction. Initial conceptual designs and operational philosophies have to address the possibilities of a major incident occurring and provide measures to prevent or mitigate such events.

1.1 Historical Background

The first commercially successful oil well in the US was drilled in August 1859 in Titusville (Oil Creek), Pennsylvania by Colonel Edwin Drake (1819–1880). Few people realize that Colonel Drake’s famous first oil well caught fire and some damage was sustained to the structure shortly after its operation. Later in 1861, another oil well at Oil Creek, close to Drake’s well, caught fire and grew into a local conflagration that burned for 3 days causing 19 fatalities. One of the earliest oil refiners in the area, Acme Oil Company suffered a major fire loss in 1880, from which it never recovered. The state of Pennsylvania passed the first anti-pollution laws for the petroleum industry in 1863. These laws were enacted to prevent the release of oil into waterways next to oil production areas. At another famous and important early US oil field named Spindletop (discovered in 1901) located in Beaumont, Texas, an individual smoking set off the first of several catastrophic fires, which raged for a week, only 3 years after the discovery of the reservoir. Major fires occurred at Spindletop almost every year during its initial production. Considerable evidence is available that hydrocarbon fires were a fairly common sight at early oil fields. These fires manifested themselves as either from man-made, natural disasters, or from deliberate and extensive of the then unmarketable reservoir gas. Hydrocarbon fires were accepted as part of the early industry and generally little efforts were made to stem their existence. See Figures 1.1 and 1.2.

Figure 1.1 Spindletop gusher. photo credit: American Petroleum Institute

Figure 1.2 Early petroleum industry fire incident.

Offshore drilling began in 1897, just 38 years after Colonel Edwin Drake drilled the first well in 1859. H.L. Williams is credited with drilling a well off a wooden pier in the Santa Barbara Channel in California. He used the pier to support a land rig next to an existing field. Five years later, there were 150 offshore wells in the area. By 1921, steel piers were being used in Rincon and Elwood (California) to support land-type drilling rigs. In 1932, a steel-pier island (60 × 90 ft with a 25-ft air gap) was built one half mile offshore by a small oil company, Indian Petroleum Corporation, to support another onshore-type rig. Although the wells were disappointing and the island was destroyed in 1940 by a storm, it was the forerunner of the steel-jacketed platforms of today.

Offshore ultra deepwater wells are now costing more than $50 million, and some wells have cost more than $100 million. It is very difficult to justify wells that cost this much given the risks involved in drilling the unknown. The challenge to the offshore industry is to drill safely and economically, which means technology of economics, with safety, environment, security, and personnel health all playing a large role.

The first oil refinery in the world was built in 1851 in Bathgate, Scotland by Scottish chemist James Young (1811–1883) who used oil extracted from locally mined torbanite, shale, and bituminous coal to distill naphtha and lubricating oils that could light lamps or be used to lubricate machinery. Shortly afterwards, Ignacy Łukasiewicz (1822–1882), a pharmacist, opened an oil distillery, which was the first industrial oil refinery in the world, around 1854–1856, near Jasło, then Galicia in the Austrian Empire, and now Poland. These refineries were initially small as there was no real demand for refined fuel at that time. The plant initially produced mostly artificial asphalt, machine oil, and lubricants. As Łukasiewicz’s kerosene lamp gained popularity, the refining industry grew in the area. The refinery was destroyed in a fire in 1859.

The world’s first large refinery opened in Ploieşti, Romania, in 1856–1857, with US investment. In the 19th century, refineries in the US processed crude oil primarily to recover the kerosene. There was no market for the more volatile fraction, including gasoline, which was considered waste and was often dumped directly into the nearest river. The invention of the automobile shifted the demand to gasoline and diesel, which remain the primary refined products today.

Ever since the inception of the petroleum industry, the level of incidents for fires, explosions, and environmental pollution that has precipitated from it, has generally paralleled its growth. As the industry has grown, so has the magnitude of the incidents that have occurred. The production, distribution, refining, and retailing of petroleum taken as a whole represents the world’s largest industry in terms of dollar value. Relatively recent major high profile incidents such as Flixborough (1974), Seveso (1976), Bhopal (1984), Shell Norco (1988), Piper Alpha (1988), Exxon Valdez (1989), Phillips Pasadena (1989), BP Texas City (2005), Buncefield, UK (2005), Puerto Rico (2009), and Deepwater Horizon/British Petroleum (2010) have all amply demonstrated the loss of life, property damage, extreme financial costs, environmental impact, and the impact to an organization’s reputation that these incidents can produce.

After the catastrophic fire that burned ancient Rome in 64 A.D., the emperor Nero rebuilt the city with fire precaution measures that included wide public avenues to prevent fire spread, limitations in building heights to prevent burning embers drifting far distances, provision of fireproof construction to reduce probabilities of major fire events, and improvements to the city water supplies to aid firefighting efforts. Thus, it is evident that basic fire prevention requirements such as limiting fuel supplies, removing available ignition sources (wide avenues and building height limitations), and providing fire control and suppression (water supplies) have essentially been known since civilization began.

Amazingly to us today, Heron of Alexandria, the technical writer of antiquity (circa 100 A.D.) describes a two cylinder pumping mechanism with a dirigible nozzle for firefighting in his journals. It is very similar to the remains of a Roman water supply pumping mechanism on display in the British Museum in London. Devices akin to these were also used in the 18th and 19th century in Europe and America to provide firefighting water to villages and cities. There is considerable evidence that society has generally tried to prevent or mitigate the effects of fires, admittedly after a major mishap has occurred.

The hydrocarbon and chemical industries have traditionally been reluctant to immediately invest capital where direct return on the investment to the company is not obvious and apparent, as would any business enterprise. Additionally, fire losses in the petroleum and chemical industries were relatively small up to the 1950s. This was due to the small size of the facilities and the relatively low value of oil, gas, and chemicals to the volume of production. Until 1950, a fire or explosion loss of more than $5 million dollars had not occurred in the refining industry in the US. Also in this period, the capital-intensive offshore oil exploration and production industry was only just beginning. The use of gas was limited in the early 1900s.Typically production gas was immediately flared (i.e., disposed of by being burnt off) or the wall was capped and considered an uneconomical reservoir. Since gas development was limited, large vapor cloud explosions were relatively rare and catastrophic destruction from petroleum incidents was essentially unheard of. The outlays for petroleum industry safety features were traditionally the absolute minimum required by governmental regulations. The development of loss prevention philosophies and practices were therefore really not effectively developed within the industry until the major catastrophic and financially significant incidents of the 1980s and 1990s started to occur.

In the beginning of the petroleum industry, usually very limited safety features for fire or explosion protection were provided, as was evident by the many early blowouts and fires. The industry became known as a risky operation or venture, not only for economic returns, but also for safety (loss of life and property destruction) and environmental impacts, although this was not well understood at the time.

The expansion of industrial facilities after World War II, construction of large integrated petroleum and petrochemical complexes, increased development and use of gas deposits, coupled with the rise of oil and gas prices of the 1970s have sky-rocketed the value of petroleum products and facilities. It also meant that the industry was awakened to the possibility of large financial loses if a major incident occurred. In fact, fire losses greater than $50 million dollars were first reported during the years 1974 and 1977 (i.e., Flixbourough, UK, Qatar, and Saudi Arabia). In 1992, the cost just to replace the Piper Alpha platform and resume production was reportedly over $1 billion dollars. In 2005 the Buncefield incident cost was over $1,221,000,000 dollars (£750 million UK pounds reported in insurance claims). In some instances, legal settlements have been financially catastrophic, e.g., Exxon Valdez oil spill legal fines and penalties were $5 billion dollars. In 2009, the Occupational Safety and Health Administration (OSHA) proposed it largest ever fine, $87 million dollars against British Petroleum (BP) for a lack of compliance with safety regulations and agreed-upon improvements at the Texas City refinery, after the explosion of 2005. It has already paid out more than $2 billion dollars to settle lawsuits from the incident.

It should also be remembered that a major incident may also force a company to literally withdraw from that portion of the business sector where public indignation, prejudice, or stigma toward the company strongly develops because of the loss of life suffered. The availability of 24 h news transmissions through worldwide satellite networks, cell phone cameras and texting, or via the internet, emails, and its blogs, virtually guarantees a significant incident in the petroleum or chemical industry will be known worldwide very shortly after it occurs, resulting in immediate public reaction and the thought of lawsuits.

Only in the last several decades has it been well understood and acknowledged by most industries that fire and explosion protection measures may also be operational improvement measures, as well as a means of protecting a facility against destruction. An example of how the principle of good safety practice equates to good operating practice is the installation of an emergency isolation valve at a facility’s inlet and outlet pipelines. In an emergency they serve to isolate fuel supplies to an incident and therefore limit damage. They could also serve as an additional isolation means to a facility for maintenance or operational activities when a major facility isolation requirement occurs (e.g., Testing and Inspection (T&Is), Turnarounds, new process/project tie-ins, etc.). It can be qualitatively shown that it is only limitations in practical knowledge by those involved in facility construction and cost implications that have generally restricted practical applications of adequate fire protections measures throughout history.

Nowadays safety features should hopefully promulgate the design and arrangement of all petroleum and chemical facilities. In fact, in highly industrial societies, three features must demonstrate to the regulatory bodies that the facility has been adequately designed for safety before permission is given for their construction. It is thus imperative that these measures are well defined early in the design stage in order to avoid costly project change orders or later incident remedial measures expenses required by regulatory bodies. Industry experience has demonstrated that revising a project design in the conceptual and preliminary stages for safety and fire protection features is more cost effective than performing the reviews after the designs has been completed. The Cost Influence Curve for any project acknowledges that 75% of a project cost is defined in the first 25% of design. On average the first 15% of the overall project cost is usually spent on 90% of the engineering design. Retrofit or modification costs are estimated at 10 times the cost after the plant is built and 100 times after an incident occurs. It should be realized that fire protection safety principles and practices are also prudent business measures that contribute to the operational efficiencies of a facility. Where this is not realized by management it contributes to the root cause(s) of an incident eventually occurring. Most of these measures are currently identified and evaluated through a systematic and thorough risk analysis role.

1.2 Legal Influences

Before 1900, US industry and the federal government generally paid little notice to the safety of industrial workers. Only with the passage of the Workmen’s Compensation laws in the US between 1908 and 1948 did businesses start to improve the standards for industrial safety. Making the work environmentally safer was found to be less costly than paying compensation for injuries, fatalities, governmental fines, and higher insurance premiums. Labor shortages during World War II focused renewed attention on industrial safety and on the losses incurred by industrial incidents, in order to maintain production output available for the war effort. In the 1950s, 1960s, and 1970s a number of industry specific safety laws were enacted in the US due to increasing social and political pressure to improve safety and health of workers and the realization by the government of the existence of technically outdated standards, poor enforcement, and their obvious ineffectiveness. They included the Coal Mine Health and Safety Act (1952 and 1969), the Metal and Nonmetallic Mine Safety Act (1966), the Construction Safety Act (1969), and the Mine Safety and Health Act (1977). All of this legislation mandated safety and fire protection measures for workers by the companies employing them.

1.2.1 Occupational Safety and Health Administration (OSHA)

A major US policy toward industrial safety measures was established in 1970, when for the first time all industrial workers in businesses affected by interstate commerce were covered by the Occupational Health and Safety Act (1970), 29 CFR Part 1910. Under this act, the National Institute for Occupational Safety and Health (NIOSH) was given responsibility for conducting research on occupational health and safety standards, and the Occupational Safety and Health Administration (OSHA) was charged with setting, promulgating, and enforcing appropriate safety standards in industry.

The Occupational Safety and Health Administration, under the US Department of Labor, publishes safety standards for both general industry as well as specific industries, including the petroleum and chemical industries. OSHA requires accident reporting and investigation for all regulated industries, which includes the petroleum and chemical industries. OSHA also issued the Process Safety Management of Highly Hazardous Chemicals standard (29 CFR 1910.119). Process Safety Management (PSM) is addressed in specific standards for the general and construction industries. OSHA’s standard emphasizes the management of hazards associated with highly hazardous chemicals and establishes a comprehensive management program that integrates technologies, procedures, and management practices.

1.2.2 Chemical Safety and Hazard Investigation Board (CSB)

In 1990, the US Clean Air Act authorized the creation of an independent Chemical Safety and Hazard Investigation Board (CSB), but it did not become operational until 1998. Its role, as defined by 40 CFR Part 1600, is to solely investigate chemical incidents to determine the facts, conditions, and circumstances which led up to the event and to identify the cause, probable cause or causes so that similar chemical incidents might be prevented. Its mandate is significantly different than a regulatory enforcement body, as it does not limit the investigation to only determine if there was a violation of an enforceable requirement, but to determine the cause or the causes of an incident. An assumption stated in the overview for the CSB is that it estimated that annually there would be 330 catastrophic incidents and of these, between 10 and 15 would be major catastrophic incidents with life loss. This is an alarming prediction for the industry and clearly indicates some improvement is needed.

It is interesting to note that the CSB does not maintain a comprehensive incident database or compile national statistics on petroleum or chemical industry incidents, nor do they summarize the incident investigations for root causes or trend analysis. At the present time, no such comprehensive statistics or analysis exist within the federal government for the petroleum or chemical industries for serious incidents such as those the CSB investigates. Separately the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA), the National Response Center (NRC), the Agency for Toxic Substances and Disease Registry (ATSDR), and other agencies maintain certain incident databases that vary in scope, completeness, and level of detail. Therefore, although the CSB is helpful in individual incident investigations, an examination by it of its overall recommendation root causes or trends in incidents would be of high benefit to industry and the safety profession.

1.2.3 DOT/PIPA Guidelines

In 2010, the Pipelines and Informed Planning Alliance (PIPA) developed a report, Partnering to Further Enhance Pipeline Safety Through Risk-Informed Land Use Planning, which offers nearly 50 recommended practices for communities, developers, and pipeline operators to use to help reduce safety risks that result from community growth near pipelines. The US DOT said the recommendations explain how land use planning and development decisions can help protect existing pipelines. They also provide recommendations on how communities can gather information about local pipelines; about how local planners, developers, and pipeline operators should communicate during all development phases; and how to minimize pipeline damage from excavation during site preparation and construction.

1.2.4 BSEE, Safety and Environmental Management Systems

Also in 2010, the Bureau of Safety and Environmental Enforcement (BSEE), part of the US Department of Interior, published the Final Rule for 30 CFR Part 250 Subpart S—Safety and Environmental Management Systems (Ref. US Federal Register, 75 FR 63610). The BSEE enforces safety and environmental protection on the 1.7 billion-acre US Outer Continental Shelf (affecting offshore oil and gas development). This Final Rule incorporates by reference, and makes mandatory, the American Petroleum Institute’s Recommended Practice for Development of a Safety and Environmental Management Program for Offshore Operations and Facilities (API RP 75), Third Edition, May 2004, reaffirmed May 2008. This recommended practice, including its appendices, constitutes a complete Safety and Environmental Management System (SEMS).

API RP 75 consists of 13 sections, one of which is a General section. This relates to the 12 elements identified in the ANPR and states the overall principles for the SEMS and establishes management’s general responsibilities for its success. The General element is critical to the successful implementation of the SEMS in API RP 75, and the BSEE is incorporating this standard by reference with some of the BSEE prescriptive requirements. The BSEE believes that adoption of API RP 75 in its entirety is consistent with the direction of the National Technology Transfer and Advancement Act of 1996, which directs agencies, whenever possible, to adopt private standards. The Final Rule became effective on November 15, 2010. The Final Rule applies to all US Outer Continental Shelf (OCS) oil and gas and sulfur operations and the facilities under the BSEE jurisdiction including drilling, production, construction, well workover, well completion, well servicing, and Department of Interior pipeline activities.

1.2.5 National Institute of Occupational Safety and Health (NIOSH)

According to the Centers for Disease Control (CDC), part of the National Institute of Occupational Safety and Health (NIOSH), in a report prepared by the National Occupational Research Agenda (NORA), the US oil and gas extraction industry had during 2003–2008, 648 oil and gas extraction worker fatal injuries on the job, resulting in an occupational fatality rate of 29.1 deaths per 100,000 workers—eight times higher than the rate for all US workers. Two goals set by NORA are to, by the year 2020, reduce the occupational fatality rate by 50% and reduce the rate of non-fatal occupational injuries by 50% for workers in the oil and gas extraction industry.

1.2.6 Security Vulnerability Assessment (SVA) Regulation

In March 2003, the United States implemented Operation Liberty Shield to increase the readiness and security in the United States primarily due to international threats from non-government affiliated self-motivated political and religious groups. One objective of this operation is to implement comprehensive process security management programs into existing OSHA, EPA, and FDA laws to address deliberate acts of threats of terrorism, sabotage, and vandalism. In April 2007, the Department of Homeland Security (DHS) issued the Chemical Facility Anti-Terrorism Standard (CFATS). The purpose of DHS is to identify, access, and ensure effective security at high risk chemical facilities. Included in this responsibility is the requirement for chemical facilities handling chemicals above a threshold amount to submit a SVA for DHS review and approval along with a site security plan (SSP). A potential fine of $25,000/day, an inspection and audit by DHS, or an order to cease operations is stated for noncompliance. The type and amount of chemicals handled which require submission of screening review and SVA submittals are listed on the DHS website. Additionally, internal company security procedures, although confidential, would also require that an adequate security review be undertaken to identify and assess such risks. Since the methodology of conducting process security reviews is similar to existing process hazard analysis reviews, they can be adapted to fit within the parameters of existing procedures established for these analyses. Both API and AIChE have also issued their own guidelines to assist companies undertaking process security reviews. A major process safety consultant recently stated that statistics show that the use of outside security experts for protective services consultations has increased by 200% in the last 5 years. This is due to escalating concerns over workplace and domestic violence, privacy and security practices, and terrorist threats. Process security reviews are not intended to identify minor thefts or mishaps; these are the responsibility of the company’s general security requirements that are well established and can be examined with other financial auditing